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Strategic analysis on global tax architecture, corporate structuring, regulatory frameworks, and cross-border operations.
The UK non-dom regime ended on 6 April 2025, and Dubai is the natural destination for much of the wealth that left with it. But moving does not switch off UK inheritance tax. Once you have been UK resident for 10 of the last 20 years, your worldwide estate stays in the 40% net for a three-to-ten-year tail after you go.
There is no single number of days that makes you non-resident when you move from the UK to Dubai. The Statutory Residence Test decides it, and it can keep you UK tax resident at well under 183 days, or pull you back years later if you return too soon. Here is how the test works, and where movers get caught.
Read Full AnalysisYes, a UK resident can open a company in Dubai, with full foreign ownership. What the setup adverts skip is that registering a company in the UAE does not move where it is taxed. If a Dubai company is really run from the UK, HMRC can treat it as a UK company, or tax its profits in the owner's hands.
Read Full AnalysisYes, a UAE free zone company can pay 0% corporate tax in 2026. But the 0% rate is not automatic, and it does not come with the licence. It belongs to a Qualifying Free Zone Person that meets five conditions every year, and one wrong transaction can move the whole company to 9% for five years.
Read Full AnalysisAfter Brexit, a UK holding company relies on the Substantial Shareholding Exemption under Schedule 7AC TCGA 1992 and the dividend exemption under CTA 2009 Part 9A, not the EU directives. For a UK-resident founder holding UAE and Irish trading subsidiaries, it is often the cleaner top company than an Irish holdco.
Read Full AnalysisFederal Decree-Law No. 17 of 2025 amended the UAE Tax Procedures Law from 1 January 2026: the audit limitation extends to fifteen years for evasion and refund claims lapse at five years. With a new penalty regime from April 2026, the FTA audit is decided by the records, not the meeting.
Read Full AnalysisA founder relocates to Dubai, opens a UAE company, and has it invoice his UK company for management services to shift profit to 0-9%. Both HMRC and the UAE Federal Tax Authority test that against the arm's length principle and the DEMPE functions. The transfer price is a position to defend, not a number to choose.
Read Full AnalysisWholesale CBDC is not a new asset class. It is tokenised central bank reserves, accessible only to banks and eligible institutions, as reserves have been for decades. For a family office across the UK-UAE corridor, access to tokenised markets runs through the custodian and the wrapper, not a central bank account.
Read Full AnalysisUAE Cabinet Decision No. 209 of 2025 took effect on 30 January 2026, replacing the 2012 exchange-of-information framework. It imposes record-keeping and disclosure duties on UAE persons, including free zone entities, that apply whether or not the entity pays corporate tax, backed by fines up to AED 100,000.
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